NBIM Urges the EU to Let Companies Meet ESRS and ISSB Requirements in a Single Report

At the end of 2025, when the European Commission closed its final consultation on the revised ESRS, Norges Bank Investment Management, or NBIM, which manages Norway's $2 trillion sovereign wealth fund, made an unusual recommendation. Build a mechanism that lets companies satisfy both ESRS and ISSB, including IFRS S1/S2, in one report. The demand stands out because it comes not from a beneficiary of regulation but from one of the largest users of disclosed information.

The Invisible Cost of Double Reporting

Many manufacturers embedded in global supply chains have had to prepare sustainability reports in different formats for different customers and investors. CSRD/ESRS for the EU, ISSB for international capital markets. The substance overlaps heavily, yet format differences alone can double the work in practice.

NBIM's comment letter to the European Commission directly calls for this double burden to be removed. It argues not only that harmonization can reduce companies' double reporting costs, but also that investors can more easily compare sustainability information across companies in different jurisdictions. The fact that NBIM manages $2 trillion and is therefore a user of the information gives the recommendation practical weight.

ISSB Adoption Signals a Structural Shift

NBIM's reason for naming ISSB as the counterpart to ESRS is the standard's rapid global adoption.

With 42 jurisdictions and about 60% of global GDP covered, a standard that has spread this far in less than two years since its June 2023 release is unlikely to remain a regional or local requirement. Japan is also seeking alignment with ISSB in sustainability disclosure within annual securities reports, making the issue increasingly close to suppliers in Asia-Pacific as well (SSBJ April 2027 application and supplier preparation). NBIM explicitly describes ISSB as the global baseline for sustainability reporting and asks the European Commission to align ESRS with it.

ESRS Has Already Been Sharply Reduced, and the Scale Is Visible in the Numbers

At the same time, ESRS requirements themselves have changed dramatically over the past year. In December 2025, the European Financial Reporting Advisory Group, EFRAG, submitted its final proposal for the revised ESRS to the European Commission. Before that, the Omnibus package also sharply narrowed the number of companies subject to mandatory CSRD application.

The chart shows that the EU has acknowledged the weight of ESRS. Voluntary disclosure items have been removed, mandatory data points have been cut by 61%, and the total reduction is more than 70%. For CSRD, the threshold has been raised from more than 250 employees to revenue of at least EUR 450 million and more than 1,000 employees, reducing the number of covered companies by about 90%.

For mid-sized manufacturing suppliers, this threshold change alone may remove the direct CSRD obligation. However, indirect data requests through European customers and financial institutions will remain in the form of value-chain inquiries, so it is risky to conclude that no obligation means no need to prepare.

What Changes If Integration Happens

It is not yet clear whether NBIM's request will be reflected in future regulatory design. Still, it is possible to outline what would change if that direction becomes reality.

The Order of Work to Start Now

The practical decision points can be organized now. First, confirm whether the company falls under the new CSRD threshold of revenue of at least EUR 450 million and more than 1,000 employees. If it is below the threshold, direct application may not arise for the time being, but it is still worth improving GHG emissions data quality in anticipation of value-chain inquiries from European customers.

For ISSB readiness, adoption in 42 jurisdictions and about 60% of global GDP suggests that the standard will be difficult to avoid over the medium term for companies engaged in global capital raising or transactions. Whether ESRS and ISSB eventually converge or not, building the data collection system required by IFRS S2 for climate-related financial information, including Scope 1-3 emissions and financial impacts of climate risk, is useful preparation in either scenario.

NBIM's move points to convergence, not simple regulatory relaxation. If report formats are unified, expectations for the quality and comparability of disclosed content may become stricter. There is still a lot that can be prepared now.

Sources

• ESG Today — NBIM Calls on EU to Allow Companies to Meet ESRS and ISSB Requirements in a Single Report (specialist media coverage of NBIM's comment letter)